The costs of appeal are assessed against the plaintiff.

In light of the various circumstances acknowledged in its holding, the lower court determined that it cannot be readily concluded that the title trust of the instant shares to the Plaintiffs derived from the purpose of management necessity regardless of tax avoidance, and rejected the Plaintiffs’ assertion that there was no purpose of tax avoidance in the title trust of the instant shares, and that Article 45-2(1) of the Inheritance Tax and Gift Tax Act (amended by Act No. 8828 of Dec. 31, 2007), which served as the basis of the instant disposition, did not constitute an infringement on the right to equality by infringing on the property rights of the title trustee or arbitrarily treating the title trustee, on the grounds as stated in its reasoning.

Examining the reasoning of the judgment below and the judgment of the court of first instance cited by the court below in light of the records, the above judgment of the court below is just and acceptable.

The judgment of the court below is not unlawful, as it is based on the ground of appeal, by misapprehending the legal principles on the constructive donation of stock title trust, or by neglecting the determination on the constitutionality of the provisions of the Inheritance Tax and Gift Tax Act.

The proposal of the grounds of appeal is without the number of days.

Therefore, all appeals are dismissed, and the costs of appeal are assessed against the losing party. It is so decided as per Disposition by the assent of all participating Justices on the bench.